Religion-Based Harassment

In October 2001, Clinton Ingram, an African-American Muslim, was hired by Sunbelt Rentals in Gaithersburg, Maryland, as a truck driver and was later promoted to rental manager. The company allowed Ingram to use a private room for daily prayer and attend weekly congregational prayer sessions on Fridays from 1-1:45 p.m. After the September 11 terrorist attacks, co-workers regularly called Ingram "Taliban" and "towel head," made fun of Ingram’s appearance, challenged his allegiance to the United States, suggested he was a terrorist and made comments associating all Muslims with senseless violence.

Ingram made repeated verbal complaints to Steve Riddlemoser, a general manager, and faxed a written complaint to the company’s human resources department. After Riddlemoser investigated and co-workers denied the comments, Riddlemoser found insufficient support for Ingram’s allegations and refused to take disciplinary action. Riddlemoser told Ingram his "performance and personality are the only cause for the problems," and that Sunbelt had been "very accommodating." Ingram’s co-workers continued to harass him until his termination in February 2003.

The EEOC filed suit in the U.S. District Court for the District of Maryland on behalf of Ingram, alleging religious harassment in violation of Title VII. The court granted summary judgment in favor of Sunbelt. The EEOC appealed.

The 4th Circuit Court of Appeals in Richmond, Virginia, reversed, holding that Sunbelt failed to prevent the harassment. Title VII does not contain a "crude environmental" exception as implied by the district court. EEOC v. Sunbelt Rentals Inc., 4th Cir. No. 07-1123 (3/31/08).

Impact: When considering appropriate responses to confirmed incidents of workplace harassment, employers are advised to take action that effectively deters recurrence of such conduct. This may include retraining employees about harassment, republishing the employer’s policy on such matters and disciplinary action against responsible parties.